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NorwayRevisorforeningen

Tax-free education: service time survives a business transfer

In BFU 7/2026, Skattedirektoratet accepts continuous service across a business transfer or restructuring, whether or not the transaction has tax continuity.

By Taxxa AI OyPublished 27 August 2026

Tax

Employees transferred with a business can retain their service time when assessing entitlement to tax-free employer-funded education.Skatteetaten In binding advance ruling 7/2026, published on 25 August 2026, Skattedirektoratet concluded that the employment period is not interrupted merely because the employer changes through a business transfer or corporate restructuring.Revisorforeningen The conclusion applies whether or not the transaction takes place with tax continuity.Revisorforeningen

For external courses lasting more than two months, the exemption requires the employee to have worked full-time for the employer for at least one year when the education starts.Skatteetaten The ruling turns on continuity of the employment relationship: where that relationship continues under the employment contract and applicable employment rules, time worked before the transfer counts towards the requirement. A change in the employer's legal identity is not decisive by itself.Skatteetaten

The applicant planned two acquisitions. Part of one business would move through a demerger and merger; the other transaction was an ordinary business transfer. Both businesses had employees already on study leave with employer-funded education, as well as employees who intended to begin education after meeting the qualifying conditions.

For employees already studying, the directorate concluded that the education benefits could continue tax-free after transfer.Skatteetaten For those yet to start, earlier service remained relevant to the one-year test, provided the qualifying period was completed before education began.Skatteetaten In the transactions described, the acquiring company therefore did not have to withhold tax or calculate employer contributions on the covered education costs.Skatteetaten

The ruling assumes that the other conditions for tax-free education are met. It also accepts the applicant's account of the employment-law effects without separately deciding those questions. Advisers applying the ruling should therefore establish that the employment relationship actually continues and assess the remaining exemption conditions, rather than treating an acquisition alone as sufficient.

The legal basis is FSFIN § 5-15-14 third paragraph, interpreted in Skattedirektoratet's BFU 7/2026.

Check employment continuity and the remaining exemption conditions before carrying service time across a transfer for employer-funded education.

Sources